Transfer Pricing(TP) report shall be submitted within one month
In compliance with regulatory requirements, companies mandated to prepare Transfer Pricing reports are obliged to submit the TP report within one month of the tax authority initiating an audit. The Tax Bureau has outlined the following key points for self-assessment:
- Transaction-based Analysis: The analysis should be based on each transaction, except for cases where there is a clear correlation or continuity between transactions.
- Disaggregated Analysis: Rather than comparing figures for the entire group, transactions should be analyzed respectively.
- Comprehensive Coverage: All controlled transactions should be thoroughly analyzed without any omissions.
- Economic Substance: Analysis should be rooted in economic substance and be reflecting the true nature of the transactions.
- Appropriate Methodology Selection: Selecting suitable conventional trading methods and profit rate indicators, and providing a clear rationale for the selection.
- Reorganized companies: analyses for both pre- and post-reorganization periods
- Intangible assets comparable transactions: should be conducted the analysis on economic activities such as development, enhancement, maintenance, protection and utilization
